Transfer pricing adjustments for software services, corporate guarantees, expense characterisation and foreign tax credit affirmed under arm's length ...
Scientific Research approval for Sikshya O Anusandhan under section 35(1)(ii) granted subject to reporting, certification, and compliance requirements...
The sole issue is validity of reassessment where notices under section 143(2) were issued manually without a computer-generated DIN. Relying on the CBDT circular making DIN mandatory from 01.10.2019 and permitting manual issue only with recorded reasons and prior written approval of CCIT/DGIT, the tribunal found Revenue could not produce recorded reasons or prior approval. Consequently the 143(2) communications are invalid and deemed never issued; assumption of jurisdiction under section 148 is vitiated and reassessment is quashed as void ab initio. - ITAT
The sole issue is validity of reassessment where notices under section 143(2) were issued manually without a computer-generated DIN. Relying on the CBDT circular making DIN mandatory from 01.10.2019 and permitting manual issue only with recorded reasons and prior written approval of CCIT/DGIT, the tribunal found Revenue could not produce recorded reasons or prior approval. Consequently the 143(2) communications are invalid and deemed never issued; assumption of jurisdiction under section 148 is vitiated and reassessment is quashed as void ab initio. - ITAT
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